Export Control & Combating Terrorist Financing

The UAE steadfastly combats illegal financial activities, such as money laundering, and actively works to eliminate terrorist financing networks.

Safeguarding the integrity of the global financial system is in line with the UAE’s commitment to enhance its competitiveness and become a global financial center and preferred destination for business, investment and economic partnerships with countries worldwide.

A Strong and Sustainable National Framework

In 2021, the UAE established an Executive Office of Anti-Money Laundering and Counter Terrorism Financing to lead the implementation of the UAE’s whole-of-government strategy, in close coordination with regional and global entities, including the United States. This was later replaced in 2024 by the National Anti-Money Laundering and Combating Financing of Terrorism and Financing of Illegal Organizations Committee (NAMLCFTC) in an effort to further strengthen the UAE’s national system, local institutional capabilities and ensure their sustainability. The new Committee also aims to consolidate integration, communication and coordination at all local and federal levels, enhance international cooperation and partnerships with countries around the world, and develop strategies to strengthen the UAE’s status as a trusted global financial hub.

Recent steps taken by the UAE include increasing investigations and prosecutions around illicit financial transactions, boosting international cooperation and better aligning virtual asset regulation with international standards.

In September 2024, the UAE Cabinet approved a comprehensive National Strategy for Anti-Money Laundering, Countering the Financing of Terrorism and Proliferation Financing (AML/CFT/CPF) for 2024-2027. Built around 11 strategic goals supported by targeted legislative and regulatory reforms, the strategy addresses emerging threats including trade-based money laundering, third-party laundering, complex legal structures, virtual assets and advanced cybercrime. Developed using World Bank methodology and incorporating findings from the UAE's latest National Risk Assessment, the strategy emphasizes risk-based compliance, effectiveness and sustainability of the national framework.

The strategy focuses on enhancing national and international coordination, strengthening supervision of financial institutions and designated non-financial businesses, improving beneficial ownership transparency and optimizing financial data use for investigations and asset recovery. Implementation is overseen by the General Secretariat of the (NAMLCFTC), with regular progress reports submitted to the Higher Committee for Supervising the National Strategy. This initiative follows the UAE's removal from the Financial Action Task Force (FATF) Grey List in February 2024, demonstrating the country's commitment to upholding the highest international standards in protecting the integrity of the global financial system.

This was followed in October 2025 with the Federal Decree Law No. 10 of 2025, significantly strengthening the UAE’s anti-money laundering and counter-terrorist financing framework. The law introduces proliferation financing as a distinct criminal offense, lowers evidentiary thresholds by allowing knowledge to be inferred from circumstantial evidence and expands the Financial Intelligence Unit's powers to freeze funds for up to 30 days. It also facilitates international cooperation by enabling enforcement of foreign asset confiscation judgments without requiring a UAE investigation or treaty.

Penalties have substantially increased, with corporate fines reaching up to AED 100 million for serious offenses and managers facing personal liability for crimes committed with their knowledge or due to breaches of duty. The law criminalizes new activities including use of privacy-enhancing virtual assets that conceal identity, providing false beneficial ownership information and failing to comply with sanctions instructions, reinforcing the UAE's commitment to international standards ahead of the FATF's 2026 evaluation.

The UAE Strongly Supports and Fully Enforces UN Sanctions

The UAE is unwavering in its obligation under Chapter VII of the United Nations Charter and relevant EU Council Resolutions to freeze, without delay, all funds or other assets of any person, group or entity  associated with Iran’s or the Democratic People’s Republic of Korea’s nuclear or ballistic missile activities, as designated by the UN Security Council or a relevant UN Security Council Committee. The UAE works to ensure that no funds or other assets are made available to or for the benefit of any such person, group or entity, either by a UAE national or any person or entity within UAE territory.

A Stringent Export Control Law with Stiff Penalties

The UAE has tightened export control laws and enforcement to prevent the movement of illicit goods and materials across its borders. In August 2007, the UAE government enacted a stringent export control law that includes stiff penalties for parties involved in the diversion of controlled shipments.

To help implement this law, the UAE Cabinet formed the UAE Committee on Commodities Subject to Import and Export Control, which includes representatives from across the UAE government. 

These measures are in line with the UAE’s vision of maintaining security and stability in the UAE and abroad.

Strong Enforcement Leads to Interdiction

As a result of the law, the UAE has shut down dozens of international and local companies involved in money laundering and proliferation of dual-use and dangerous materials banned under the Nonproliferation Treaty and multiple UN resolutions. UAE security forces have interdicted scores of ships suspected of carrying illicit cargo, based on intelligence from its own and third-country agencies.

The UAE Works with US Partners

The UAE and related agencies and companies are involved in bilateral and multilateral initiatives designed to enhance safety and control processes:

  • The UAE joined the Nonproliferation Treaty in 1996, is a member of the International Atomic Energy Agency, and cooperates with the Missile Technology Control Regime.
  • The UAE participates in the US Container Security Initiative (CSI), a security regime that includes a team of US Customs and Border Protection officers permanently stationed inside Dubai's ports, where they work closely with Dubai Customs to screen containers destined for the United States.
  • The UAE worked with the US Department of Energy to implement the Megaports Initiative, a multinational effort aimed at deterring terrorists from using the world's seaports to ship illicit materials; detecting nuclear or radioactive materials if shipped via sea cargo; and interdicting harmful materials so they cannot be used by terrorists.
  • The UAE is a signatory to the Arab Convention for the Suppression of Terrorism.
  • Ports operated by Dubai Ports World participate in the Security Freight Initiative, a US Department of Homeland Security program to test the methods used to screen US-bound cargo for radiation.
  • The UAE is a signatory to the Proliferation Security Initiative (PSI), which is aimed at stopping shipments of weapons of mass destruction, their delivery systems and related materials worldwide.
  • Dubai Ports World has been certified as a partner in the Customs-Trade Partnership Against Terrorism, a government-business cargo security initiative led by the US Department of Homeland Security.
  • The US Department of State, through its Export Control and Related Border Security Assistance program, is helping the UAE improve its enforcement and licensing capabilities aimed at curbing the transshipment of elicit materials.
  • The UAE-US Joint Task Force to Combat Money Laundering and Terrorist Financing enhances cooperation, coordination and information sharing to shut down terrorist financing networks and cut off the flow of funds to extremists.
  • The Task Force helps block funding to extremists from individuals and commercial activity such as black market sales of oil and prevents access to the international banking system.

The UAE Fights Terrorist Financing 

The UAE has frozen the accounts of known terrorists and enacted aggressive anti-money laundering initiatives. New counter-terrorist financing laws and regulations have been introduced and enforced. The UAE:

  • Committed to the International Convention on the Suppression of the Financing of Terrorism in 2005.
  • Ratified the UN Convention Against Transnational Organized Crime in 2007.
  • Is a member of the Middle East and North Africa Financial Action Task Force (MENAFATF), which facilitates international cooperation against terrorist financing.
  • Belongs, through the Gulf Cooperation Council, to the Financial Action Task Force, which supports non-proliferation principles and enforcement.
  • Created a financial intelligence unit andan Anti-Money Laundering and Suspicious Cases Unit, and is a member of the Egmont Group of Financial Intelligence Units.
  • Enacted a law in 2018 to ensure compliance with international standards on anti-money laundering and countering terrorist financing policy.
    • The law implements frameworks for monitoring credit standing, disclosure, compliance and governance procedures in the operations of the Central Bank of the UAE, to ensure confidence in the national economy.
  • In 2024, the UAE established a National Anti-Money Laundering and Combating Financing of Terrorism and Financing of Illegal Organizations Committee to oversee the implementation of the UAE’s national AML/CFT strategy  in close coordination with the Financial Action Task Force (FATF) and other regional and global entities.
  • In 2024, the FATF announced the UAE’s completion of all 15 recommendations of its action plan and congratulated the UAE on this achievement.

Enhanced Financial Monitoring 

  • The UAE supports strict enforcement of counter-terrorist financing laws and regulations, encouraging increased monitoring of charitable fundraising and further examination of money flows across the region.
  • The Central Bank of the UAE established a dedicated Department in August 2020 to handle all Anti-Money Laundering and Combatting the Financing of Terrorism matters (AML/CFT). Through this effort, the Central Bank coordinates closely with the UAE’s National AML/CFT Committee to effectively implement the National Action Plan.

                                     What Others Are Saying

Wally Adeyemo, Deputy Secretary of the Treasury

“I want to start by commending [the UAE’s] commitment to building robust systems for preventing money laundering and protecting your institutions from being used for illicit purposes, including the financing of terrorist activity. I know this is only possible because of the strong public and private partnership that exists between [the UAE] government and financial sector.”

David. S Cohen, Deputy Director of the Central Intelligence Agency; Former Under Secretary of the Treasury for Terrorism and Financial Intelligence

“[The United States is] working especially closely with our friends in the Gulf – who are stalwart partners in the anti-ISIL coalition – to ensure that they all have the tools in place to combat terrorist financing and that they all use those tools effectively.  We appreciate the close collaboration and strong steps taken by the Emiratis… to combat ISIL financing.”

 

Stuart Levey, Former US Treasury Undersecretary for Terrorism and Financial Intelligence

“There is a very strong alliance on all issues between the US and the UAE and the issue of Iran as well.  They also take seriously their commitments as a country that has articulated its support for the Financial Action Task Force principles and they take very seriously the future of their financial system and the reputation of their financial system.”

 

The Washington Institute for Near East Policy, November 2008

“The UAE has been particularly willing to take on difficult challenges in this area [terrorist financing].  … The UAE was forward-leaning in its attempts to tackle these issues. … More recently, the UAE also launched an initiative to try to regulate the many brokers located there. … The UAE has taken some other important steps recently to more closely regulate its business sector. In August 2007, the UAE passed a law allowing it to restrict exports for national security reasons. Soon after, the Emiratis detained a ship bound for Iran to determine whether chemicals on board violated either the UN resolutions or its recently passed export-control law.”

The Money Trail: Finding, Following, and Freezing Terrorist Finances

Joint Hearing Before the House Committee on Foreign Affairs – April 2018

“Over the past few years, the UAE has taken a number of joint actions with the United States against exchange houses involved in illicit activity, including closing AI Zarooni Exchange, which the United States tied to a global money laundering organizations, and cutting off a Yemen-based exchange house that was providing financial services to AI Qaeda in the Arabian Peninsula (AQAP). "

Grading Counterterrorism Cooperation with the GCC States

Joint Hearing Before the House Committee on Foreign Affairs – April 2018